Agencies | Governor
Virginia Regulatory Town Hall
Virginia Department of Health
State Board of Health
Regulations for Licensure of Abortion Facilities [REPEALED] [12 VAC 5 ‑ 412]
Action Regulations for Licensure of Abortion Facilities
Stage Proposed
Comment Period Ends 3/29/2013
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3/29/13  1:11 pm
Commenter: Dr. Tanya Arney

Please Consider Revisions Before Implementation of Proposed Regulations.

To Whom it May Concern, 


As a medical professional, I am dissapointed with TRAP. While I support standards to ensure patient safety, I do not support all of the clinical guidelines in the temporary regulations. For this reason, the Board should partner with the National Abortion Federation and other professional bodies to review and revise. The current guidelines cross a clincal boundary that evokes a non-objective, non-clinical understanding of the nature of these procedures. What is worse, is these regulations clearly pick the winners and losers of the healthcare industry by reducing and/or eliminating healthcare access and the freemarket opportunities for physicians to provide a service to women in need. Additionally, these clinics are providers of reduced and free women's prevenative health services. Furthermore, I am most appalled by the subjectiveness of these regulations, as they clearly state a personal bias against abortion providers. 

The truth is, this is not about clinics, it is about restricting access and finding a loophole to put clinics out of business in a feeble attempt to end abortion in Virginia, by eliminating the providers of such a service. 

You know as well as I do: TRAP has absolutely nothing to do with protecting women’s health. Instead, these onerous regulations are designed to force the majority of women’s health centers in Virginia to close, and prevent Virginia women from exercising their constitutional right to safe, legal abortion.



Tanya Arney, PhD, DBE, MA

Virginia Beach, Virginia

CommentID: 27701